Cited by

Lehn, 246 Ariz. at 284, ¶ 20; ¶ 4 (App. 2008).

¶ 10 (App. 2008) (stating that claim preclusion applies to issues actually litigated and “also upon those points which might have been litigated”) (quoting Gilbert v. Bd.

See Phoenix Newspapers, Inc. v. Dep’t of Corrs., (claim preclusion applies if “no additional evidence is needed to prevail in the second action than that needed in the first”); –33, ¶ 9 (App. 2008) (father’s action was “an attempt to relitigate one of the same matters necessarily adjudicated in Mother’s divorce action,” and “any further litigation on his part is not a separate or distinct cause of action”).

Although the superior court did not rely on the doctrine of issue preclusion, the District raised it as a defense, and “we will affirm the court’s ruling[s] on any legal theory supported by the record.” ¶ 4 (App. 2008).

¶ 4 (App. 2008) (claim preclusion “binds the same party standing in the same capacity in subsequent litigation on the same cause of action, not only upon facts actually litigated but also upon those points which might have been litigated”) (emphasis added).

“[Res judicata] is a question of law and is therefore reviewed de novo.” ¶ 4

–33, ¶¶ 8–9 (App. 2008) (applying the same evidence test to a paternity action controlled by state law), and Power Road-Williams Field LLC v. Gilbert, 14 F. Supp. 3d 1304, 1309 (D. Ariz. 2014) (recognizing the same evidence test as Arizona’s standard for claim preclusion), with Gila River, 212 Ariz. at 69, ¶ 13 (d

Ass’n, 455 U.S. 691, 710 (1982) (“A party cannot escape the requirements of full faith and credit or res judicata by asserting its own failure to raise matters clearly within the scope of a prior proceeding.”); ¶ 1 (App. 2008) (holding that res judicata bars re-litigation of matters actually litigated in a prior action as well as issues that might have been litigated); see also Brooks v. Trs.

533, ¶¶ 8, 10 (App. 2008) (claim preclusion applies if the evidence needed to sustain the second action would have sustained the first).

¶ 4 (App. 2008); see ARCAP 13(b)(2) (appellate 2 The family court found that the disparity in income between the parties was “not significant.” See A.R.S.

¶ 4, (citation omitted).